Complaint for Permanent Injunction and Ancillary Relief

State of California - Department of Corporations
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25. The Commissioner issued an Order Imposing Penalties and Ancillary Relief on
February 1, 2011.
26. The Order required Defendants, jointly and severally, to pay penalties and
restitution. The Order also required Defendants to pay to Plaintiff certain costs and fees.
27. To this date, Defendants have not made any such payments. As such, Defendants
are in violation of the Order issued by the Commissioner.
28. Section 25530(a) of the California Corporations Code provides that when it appears
that any person has engaged in a violation of any order issued under the Corporate Securities Law
of 1968, the Commissioner may bring an action in the name of the People, in the Superior Court,
to enjoin violation of and enforce compliance with the order.
29. The Commissioner seeks an injunction requiring Defendants to comply with the
Order. Unless enjoined by this Court, Defendants will continue to violate the Order.
30. Section 25530(b) of the California Corporations Code provides that the
Commissioner may include in an action authorized by subdivision (a) a claim for ancillary relief,
including but not limited to, a claim for restitution or disgorgement or damages and the court shall
have jurisdiction to aware the additional relief.
31. The Commissioner seeks ancillary relief, in the form of restitution to investors and
reimbursement of investigative costs and attorneys’ fees, to effect the terms of the Order.
Ancillary relief is necessary, in the public interest and is consistent with the purposes, policies and
provisions of the Corporate Securities Law of 1968.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for a final judgment against Defendants First Fidelity
Group, LLC; First Fidelity Group, Ltd.; Joseph Lekar; Simon Shaw; and Stefan Misiraca as
follows:
I. INJUNCTIVE RELIEF
For a Permanent Injunction, pursuant to California Corporations Code section 25530:
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COMPLAINT FOR PERMANENT INJUNCTION AND ANCILLARY RELIEF